Overview
Tax Notes quoted Steptoe partners Mark Silverman and Eric Solomon in a December 6 article titled "IRS Sheds Light on Bonus Regs' Related-Party Tests." The article covers a panel discussion at Practising Law Institute's 2019 conference in Los Angeles, in which several members of the firm's tax practice spoke. Panelists discussed the government's rationale for the related transactions rule for determining if acquired property qualifies for bonus depreciation could offer practitioners a different perspective on how the rule might work.
Solomon, chairperson for the program, said that taxpayers trying to determine whether the immediate full expensing provision will apply to their transactions need "more guidance on what exactly is meant by a 'series of related transactions,'" but the IRS's underlying theory behind the rule might provide some insight.
Silverman pointed out that the proposed approach differs from the section 338 rules that allow corporations to elect to treat a stock purchase as an asset acquisition.
The full article can be read at Tax Notes (subscription required).